Process Safety Management of Highly Hazardous & Explosive Chemicals
Process Safety Management of Highly Hazardous & Explosive Chemicals
Operating Procedures, Safety Procedures & Training
Operating Procedures, Safety Procedures & Training
Now that the PHA’s Are Competed or Underway…Now that the PHA’s Are Competed or Underway… Operating
Procedures & Safety Programs Must Be Developed
PHA Information Can Be Used
Operating Operating Procedures & Safety Procedures & Safety Programs Must Be Programs Must Be DevelopedDeveloped
PHA Information PHA Information Can Be Used Can Be Used
Operating ProceduresOperating Procedures
1910.119(f)1910.119(f)1910.119(f)
Operating Procedures & Safety Programs Must Consider:Operating Procedures & Safety Programs Must Consider: Initial start-up Normal operations Temporary operations Emergency shutdown Emergency operations Normal shutdown Start-up following turnaround Consequences of deviation Steps required to correct or avoid deviation
Initial startInitial start--upup Normal operationsNormal operations Temporary operationsTemporary operations Emergency shutdownEmergency shutdown Emergency operationsEmergency operations Normal shutdown Normal shutdown StartStart--up following turnaroundup following turnaround Consequences of deviationConsequences of deviation Steps required to correct or avoid deviationSteps required to correct or avoid deviation
Operating Procedures or Standard Operating Procedures (SOP’s)
Operating Procedures or Standard Operating Procedures (SOP’s)
Where Did This Methodology Come From?
Answer: The Military
Definition: A standard operating procedure is a set of instructions having the force of a directive, covering those features of operations that lend themselves to a definite or standardized procedure without loss of effectiveness. Standard Operating Policies and Procedures can be effective catalysts to drive performance improvement and improving organizational results. Every good quality system is based on its standard operating procedures (SOPs).
Where Did This Methodology Come From?Where Did This Methodology Come From?
Answer: Answer: The MilitaryThe Military
Definition: Definition: A standard A standard operating procedureoperating procedure is a set is a set of instructions having the force of a directive, of instructions having the force of a directive, covering those features of operations that lend covering those features of operations that lend themselves to a definite or standardized procedure themselves to a definite or standardized procedure without loss of effectiveness. Standard Operating without loss of effectiveness. Standard Operating Policies and Procedures can be effective catalysPolicies and Procedures can be effective catalysts to ts to drive performance improvement and improving drive performance improvement and improving organizational results. organizational results. Every good quality system Every good quality system is is based on its standard operating procedures (SOPs).based on its standard operating procedures (SOPs).
*Readily accessible to employees
Operating ProceduresOperating Procedures Develop and implement Develop and implement written operating procedures*written operating procedures*
consistent with the process safety information and addresses consistent with the process safety information and addresses at least the following elements:at least the following elements:
Initial startInitial start--up, normal and temporary operationsup, normal and temporary operations
Normal and emergency shutNormal and emergency shut--down proceduresdown procedures
Operating limits and consequences of deviationOperating limits and consequences of deviation
Hazards presented by the processHazards presented by the process
Operating ProceduresOperating Procedures
The operating procedures addressing operating parameters will contain operating instructions about: pressure limits temperature ranges flow rates…and what to do when an upset condition occurs what alarms and instruments are pertinent if an
upset condition occurs, and other subjects.
The operating procedures addressing The operating procedures addressing operating parameters will contain operating parameters will contain operating operating instructions about:instructions about: pressure limitspressure limits temperature rangestemperature ranges flow ratesflow rates……and and what to do when an upset what to do when an upset condition occurscondition occurs what alarms and instruments are pertinent if an what alarms and instruments are pertinent if an
upset condition occurs, and other upset condition occurs, and other subjects.subjects.
Operating Procedures - Start Up…We MustOperating Procedures - Start Up…We Must
Describe normal SOP's
Describe start-up SOP's
Describe Shut-down SOP’s
Describe normal SOP'sDescribe normal SOP's
Describe startDescribe start--up SOP'sup SOP's
Describe ShutDescribe Shut--down down SOPSOP’’ss
Include Sections such as: Objectives Purpose Concerns Procedures Department Operator Equipment Involved Location Related Documents
Include Sections such as:Include Sections such as: ObjectivesObjectives PurposePurpose ConcernsConcerns ProceduresProcedures DepartmentDepartment OperatorOperator Equipment InvolvedEquipment Involved LocationLocation Related DocumentsRelated Documents
Operating Procedures - Start Up…We MustOperating Procedures - Start Up…We Must
Let’s Look at An Example…
The company Lockout/Tagout program shall be followed when The company Lockout/Tagout program shall be followed when taking the receiver out of service, while maintaining the taking the receiver out of service, while maintaining the receiver, and while returning it to service. If Linereceiver, and while returning it to service. If Line--Breaking is Breaking is required, all Linerequired, all Line--Breaking precautions described in the Breaking precautions described in the company Linecompany Line--BreakBreak Policy shall be observed. Additionally, Policy shall be observed. Additionally, proper PPE shall be immediately available, or worn in response proper PPE shall be immediately available, or worn in response to the threat level posed by the work and circumstances. to the threat level posed by the work and circumstances.
Injury to operators and others in the area. Damage to the High Injury to operators and others in the area. Damage to the High Pressure Receiver. Release of any quantity of Anhydrous Pressure Receiver. Release of any quantity of Anhydrous Ammonia refrigerant. Ammonia refrigerant.
Very Careful attention to valve positions, temperature, and Very Careful attention to valve positions, temperature, and pressure levels is extremely important to the successful pressure levels is extremely important to the successful completion of these procedures. Deviations from normal completion of these procedures. Deviations from normal operating limits could cause personal injury or death, small to operating limits could cause personal injury or death, small to catastrophic releasecatastrophic release of ammonia or environmental damage, or of ammonia or environmental damage, or evacuation of, or injury to, members of the public. We seek to evacuation of, or injury to, members of the public. We seek to prevent incidents such as: prevent incidents such as:
Concerns:Concerns:
The purpose of the TOS is to provide a description of the High The purpose of the TOS is to provide a description of the High Pressure Receiver, to define the function of the receiver, its Pressure Receiver, to define the function of the receiver, its operating conditions and limits, and consequences of deviation operating conditions and limits, and consequences of deviation from these limits; To describe controls and instrumentation and from these limits; To describe controls and instrumentation and safsafety systems, and set operating alignments.ety systems, and set operating alignments. The purpose of The purpose of the Standard Operating Procedure (SOP) is to set down the the Standard Operating Procedure (SOP) is to set down the proper steps for starting, monitoring normal operation, and proper steps for starting, monitoring normal operation, and stopping and restarting the Receiver under normal and stopping and restarting the Receiver under normal and emergency conditionsemergency conditions
Purpose:Purpose:
This procedure is designed to describe the Technical Operating This procedure is designed to describe the Technical Operating Specifications (TOS), and to set down the Standard Operating Specifications (TOS), and to set down the Standard Operating Procedures for the safe operation of Ammonia High Pressure Procedures for the safe operation of Ammonia High Pressure Receiver 1 (HPRReceiver 1 (HPR--1)1)
ObjectiveObjective
Process Safety Management Procedure - Revision HPR-1 Revision Date: 1-9-2009 by: SWD
Safety Management (PSM) coordinator, and an outside consultant Safety Management (PSM) coordinator, and an outside consultant and Date: and Date:
9/2001 plant engineer, utilities supervisor, two operators, the 9/2001 plant engineer, utilities supervisor, two operators, the Process Process Annual Review By, Annual Review By,
4/1/1998 4/1/1998 Previous Revision: Previous Revision:
Authorized By: Authorized By:
Development: Development:
4/1998 4/1998 Initial Date of Initial Date of
Documents: Documents:
Related Related
Location: Location:
National Board Number National Board Number 86648664, built in 1998, by E.L. Nickell Company. , built in 1998, by E.L. Nickell Company. MAWP: 250 psig @ 240MAWP: 250 psig @ 240。。FF
room. Data from Uroom. Data from U--11--A: Vertical Receiver, Serial Number A: Vertical Receiver, Serial Number 124011124011, ,
Ammonia High Pressure Receiver, HPRAmmonia High Pressure Receiver, HPR--1 outside the south compressor 1 outside the south compressor Equipment: Equipment:
Qualified Refrigeration Operator(s) Qualified Refrigeration Operator(s) Operator: Operator:
Refrigeration Refrigeration Department: Department:
Operating ProceduresOperating Procedures
Must be Developed for Each Equipment Operation in the Covered ProcessRefer to Block DiagramsRefer to P&IDMust Cover Normal Operating Conditions,
Normal Operating Parameters, i.e.. Pressure/Flow/Current/ etc.
Must Follow Procedures & Recommendations in PHA’s
Must Follow Form
Must be Developed for Each Equipment Must be Developed for Each Equipment Operation in the Covered ProcessOperation in the Covered Process Refer to Block DiagramsRefer to Block Diagrams Refer to P&IDRefer to P&ID Must Cover Normal Operating Conditions, Must Cover Normal Operating Conditions,
Normal Operating Parameters, i.e.. Normal Operating Parameters, i.e.. Pressure/Flow/Current/ etc.Pressure/Flow/Current/ etc.
Must Follow Procedures & Must Follow Procedures & Recommendations in PHARecommendations in PHA’’ss
Must Follow Form Must Follow Form
Operating Procedures Operating Procedures
For Shut-down Procedures…Remember:Most operations must be shut down in a
specific order! Failure to follow these shut down
procedures could results in a catastrophic release or system failure
For ShutFor Shut--down down ProceduresProcedures……Remember:Remember: Most operations must be shut down in a Most operations must be shut down in a
specific order!specific order! Failure to follow these shut down Failure to follow these shut down
procedures could results in a catastrophic procedures could results in a catastrophic release or system failurerelease or system failure
Ammonia Plant Explosion Caused by Improper Shut-down of Engine Room
Operating Procedures Operating Procedures
Operating Limits Operating Limits
Must be Understood Pressures Flows Electrical Potential Tolerances
Operating LimitsOperating Limits Operating Limits Operating Limits
Must be UnderstoodMust be Understood PressuresPressures FlowsFlows Electrical PotentialElectrical Potential TolerancesTolerances
Operating Procedures -Hazards of the ProcessOperating Procedures -Hazards of the Process Operating
Procedures Must Identify the Hazards of the Process in All Phases: Start Up Normal Operating
Conditions Temporary Operating
Condition Emergency Shut-
down
Operating Operating Procedures Must Procedures Must Identify the Hazards Identify the Hazards of the Process in All of the Process in All Phases:Phases: Start UpStart Up Normal Operating Normal Operating
ConditionsConditions Temporary Operating Temporary Operating
ConditionCondition Emergency ShutEmergency Shut--
downdown
Now That We’ve Completed the Operating Procedures
Now That We’ve Completed the Operating Procedures
We Must Develop Safety Work Practices, Programs & Procedures for Covered
Processes
We Must Develop Safety Work Practices, We Must Develop Safety Work Practices, Programs & Procedures for Covered Programs & Procedures for Covered
ProcessesProcesses
Safe Work PracticesSafe Work Practices
1910.119(f)(1)1910.119(f)(1)1910.119(f)(1)
•Develop and implement safe work practices* to provide for
the control of hazards during operations such as:
–Lockout/tagout;
–Confined space entry;
–Line Opening process equipment or piping; and
–Control over entrance into a facility by maintenance,
contractor, laboratory, or other support personnel
Safe Work PracticesSafe Work Practices
*These safe work practices apply to contractor employees as well
Safe Work PracticesSafe Work Practices
Safe Work Practices, Programs & Procedures must: Be specific to the Covered Process Follow Procedures & Recommendations in
the PHA’s Follow Procedures in the Operating
ProceduresMust be Able to be Tracked Follow Form
Safe Work Practices, Programs & Safe Work Practices, Programs & Procedures must:Procedures must: Be specific to the Covered ProcessBe specific to the Covered Process Follow Procedures & Recommendations in Follow Procedures & Recommendations in
the PHAthe PHA’’ss Follow Procedures in the Operating Follow Procedures in the Operating
ProceduresProcedures Must be Able to be TrackedMust be Able to be Tracked Follow FormFollow Form
Safe Work PracticesSafe Work Practices
Lockout Tagout - One of the Most Important Procedures in PSM
Must be Written Carefully & Follow all Procedures (PHA’s, Operating Procedures)
Must be Followed to the Letter!
Lockout Tagout Lockout Tagout -- One of the Most One of the Most Important Procedures in PSMImportant Procedures in PSM
Must be Written Carefully & Follow all Must be Written Carefully & Follow all Procedures (PHAProcedures (PHA’’s, Operating s, Operating Procedures)Procedures)
Must be Followed to the Letter!Must be Followed to the Letter!
Safe Work PracticesSafe Work Practices
Lockout/Tagout in PSM Why not Use Digital
Imaging in Your Procedures to Identify Critical Lockout /Tagout Positions
Lockout/Tagout Lockout/Tagout in in PSMPSM Why not Use Digital Why not Use Digital
Imaging in Your Imaging in Your Procedures to Identify Procedures to Identify Critical Lockout Critical Lockout /Tagout /Tagout PositionsPositions
Line Opening Permits Identify Procedures
for Opening any Process Line in a Covered Process
Must Include Hazards of the Line Opening
PPE Required
Line Opening Line Opening PermitsPermits Identify Procedures Identify Procedures
for Opening any for Opening any Process Line in a Process Line in a Covered ProcessCovered Process
Must Include Must Include Hazards of the Line Hazards of the Line OpeningOpening
PPE RequiredPPE Required
Safe Work PracticesSafe Work Practices
Safe Work PracticesLine & Equipment OpeningSafe Work PracticesLine & Equipment Opening A Hazard Review Must Completed for All
Line/Equipment Hazards Including:
HAZARDOUS MATERIALS IN SYSTEM POTENTIAL PHYSICAL HAZARDS BARRICADING AS REQUIRED FIRST AID IF EXPOSED LOCATION OF SAFETY EQUIPMENT PPE REQUIRED FOR LINE OPENING
A Hazard Review Must Completed for All A Hazard Review Must Completed for All Line/Equipment Hazards Including:Line/Equipment Hazards Including:
HAZARDOUS MATERIALS IN SYSTEMHAZARDOUS MATERIALS IN SYSTEM POTENTIAL PHYSICAL HAZARDSPOTENTIAL PHYSICAL HAZARDS BARRICADING AS REQUIRED BARRICADING AS REQUIRED FIRST AID IF EXPOSEDFIRST AID IF EXPOSED LOCATION OF SAFETY EQUIPMENTLOCATION OF SAFETY EQUIPMENT PPE REQUIRED FOR LINE OPENINGPPE REQUIRED FOR LINE OPENING
Safe Work Practices-Hot WorkSafe Work Practices-Hot WorkA Program Must be Developed for the Covered Process
That Requires: A Hot Work Permit be Issued for ALL Hot Work
Performed in the Plant by Employees or Contractors A Permit must be Posted at the Location of the Hot
Work A Fire Watch Is Required A Fire Extinguisher or Other Appropriate Fire
Fighting Equipment Must Be Present, Fire Watch must be Trained in its use
A Program Must be Developed for the Covered Process A Program Must be Developed for the Covered Process That Requires:That Requires:
A Hot Work Permit be Issued for ALL Hot Work A Hot Work Permit be Issued for ALL Hot Work Performed in the Plant by Employees or ContractorsPerformed in the Plant by Employees or Contractors
A Permit must be Posted at the Location of the Hot A Permit must be Posted at the Location of the Hot WorkWork
A Fire Watch Is RequiredA Fire Watch Is Required A Fire Extinguisher or Other Appropriate Fire A Fire Extinguisher or Other Appropriate Fire
Fighting Equipment Must Be Present, Fire Watch Fighting Equipment Must Be Present, Fire Watch must be Trained in its usemust be Trained in its use
Paper Mill Explosion & Fire Caused by Failure to Follow Hot Work Procedures
Must be Specific for the Covered Process
May Require Additional Program other than Lockout Tagout, Line Opening & Hot Work…such as Confined Space, Electrical Safe Work Practices, Combustible Dust
Must be Specific for the Covered Must be Specific for the Covered ProcessProcess
May Require Additional Program other May Require Additional Program other than Lockout Tagout, Line Opening & than Lockout Tagout, Line Opening & Hot WorkHot Work……such as Confined Space, such as Confined Space, Electrical Safe Work Practices, Electrical Safe Work Practices, Combustible Dust Combustible Dust
Safe Work PracticesSafe Work Practices
Now That We’ve Developed Safe Work Practices
Now That We’ve Developed Safe Work Practices
We Have to TrainWe Have to TrainWe Have to Train
TrainingTraining
1910.119(g)1910.119(g)1910.119(g)
PSM 29CFR1910.119(g) RequiresPSM 29CFR1910.119(g) Requires(G) Training (Initial, Refresher, and Documentation)
(paragraphs (g)(1), (g)(2), and (g)(3)).
Paragraph (g)(1) requires employers to train employees operating dangerous process. Paragraph (g)(2) requires that the employer provide refresher training at least every three years. Paragraph (g)(3) requires the employer to prepare a record that contains the name of employee, the date of training, and the means used to verify that the employee understood the training
(G) (G) Training (Initial, Refresher, and Documentation) Training (Initial, Refresher, and Documentation) (paragraphs (g)(1), (g)(2), and (g)(3)).(paragraphs (g)(1), (g)(2), and (g)(3)).
Paragraph (g)(1) requires employers to train Paragraph (g)(1) requires employers to train employees operating dangerous process. Paragraph employees operating dangerous process. Paragraph (g)(2) requires that the employer provide refresher (g)(2) requires that the employer provide refresher training at least every three years. Paragraph (g)(3) training at least every three years. Paragraph (g)(3) requires the employer to prepare a record that requires the employer to prepare a record that containscontains the name of employee, the date of training, the name of employee, the date of training, and the means used to verify that the employee and the means used to verify that the employee understood the trainingunderstood the training
PSM TrainingPSM Training
PSM Training Programs Must be Developed for: Affected Employees - Those not Directly Involved
in the Process Operation Authorized Employees - Those Directly Involved in
the Process Operation Contractors Who May Perform Work on a Covered
Process Vendors/Visitors who May Visit the Facility and
May Potentially be Exposed to the Covered Process
PSM Training Programs Must be Developed PSM Training Programs Must be Developed for:for: Affected Employees Affected Employees -- Those not Directly Involved Those not Directly Involved
in the Process Operationin the Process Operation Authorized Employees Authorized Employees -- Those Directly Involved in Those Directly Involved in
the Process Operationthe Process Operation Contractors Who May Perform Work on a Covered Contractors Who May Perform Work on a Covered
ProcessProcess Vendors/Visitors who May Visit the Facility Vendors/Visitors who May Visit the Facility and and
May Potentially be Exposed to the Covered May Potentially be Exposed to the Covered ProcessProcess
PSM TrainingPSM Training
Training Must Be Performed as Follows: Initial training Prior to work assignmentWaved for those already in a process
Refresher training Every three years
All Training Must be Documented
Training Must Be Performed as Follows:Training Must Be Performed as Follows: Initial trainingInitial training Prior to work assignmentPrior to work assignment Waved for those already in a processWaved for those already in a process
Refresher trainingRefresher training Every three yearsEvery three years
All Training Must be DocumentedAll Training Must be Documented
PSM TrainingPSM Training
Training Subjects Must Include at Least: Lockout TagoutHot Work Line & Equipment OpeningConfined Space (if applicable) Emergency Response
Training Subjects Must Include at Least:Training Subjects Must Include at Least: Lockout TagoutLockout Tagout Hot WorkHot Work Line & Equipment OpeningLine & Equipment Opening Confined Space (if applicable)Confined Space (if applicable) Emergency ResponseEmergency Response
Examples of Training Examples of Training
PSM training example including the means used to verify that the employee
understood the training.
PSM training example including the means used to verify that the employee
understood the training.
Let’s Use Hot Work ProceduresLet’s Use Hot Work Procedures
Safe Work PracticesSafe Work Practices
Hot Work ProgramHot Work ProgramHot Work Program
EXAMPLES OF HOT WORK
Safe Work Practices Hot Work Burning, Welding, Grinding
Safe Work Practices Hot Work Burning, Welding, Grinding
Our Program Requires A Hot Work Permit be Issued for ALL Hot
work Performed in the Plant by Employees or Contractors
Permit must be Posted at the Location of the Hot Work
Fire Watch Is Required Fire Extinguisher Must Be Present, Fire
Watch must be Trained in its use
Our Program RequiresOur Program Requires A Hot Work Permit be Issued for ALL Hot A Hot Work Permit be Issued for ALL Hot
work Performed in the Plant by Employees or work Performed in the Plant by Employees or ContractorsContractors
Permit must be Posted at the Location of the Permit must be Posted at the Location of the Hot WorkHot Work
Fire Watch Is RequiredFire Watch Is Required Fire Extinguisher Must Be Present, Fire Fire Extinguisher Must Be Present, Fire
Watch must be Trained in its useWatch must be Trained in its use
Safe Work PracticesHOT WORKSafe Work PracticesHOT WORKPERMIT MUST BE
COMPLETED PRIOR TO BEGINNING WORK INVOLVIING ANY HOT WORK
PERMIT SHALL BE DISPLAYED AT THE LOCATION OF THE ACTUAL HOT WORK OPERATION
PERMIT MUST BE PERMIT MUST BE COMPLETED PRIOR COMPLETED PRIOR TO BEGINNING WORK TO BEGINNING WORK INVOLVIING INVOLVIING ANY HOT ANY HOT WORKWORK
PERMIT SHALL BE PERMIT SHALL BE DISPLAYED AT THE DISPLAYED AT THE LOCATION OF THE LOCATION OF THE ACTUAL ACTUAL HOTHOT WORK WORK OPERATIONOPERATION
VERIFICATION OF UNDERSTANDING WORKSHEETHOT WORK
CIRCLE THE CORRECT ANSWER
1. A HOT WORK permit must be obtained prior to beginning HOT.work by welders and contractors before beginning a job.
TRUE
2. A HOT WORK permit is not necessary if just burning and grinding is being done on a job.
FALSE
3. Contractors are not required to obtain HOT WORK permits.FALSE
4. The employee or contractor will obtain a HOT WORK permit from his supervisor and must determine if conditions are safe and have a fire watch if necessary.
TRUE
5. HOT WORK is permitted in explosive atmospheres, around hazardous tanks and equipment.
FALSE6. The following protective measures can be used: damp sand on floors, protective shields, or fire resistant coverings while Hot Work is taking place.
TRUE
7. 35 feet is a good safe distance for covered combustibles to be away from HOT WORK.
TRUE
8. Fully charged and operable fire extinguishers and/or hose lines shall be available and ready.
TRUE
9. The HOT WORK permit shall be posted at the job site, and the supervisor shall retain the permits for three (3) days.
TRUE
10. The fire watch does not have to be trained in fire extinguishing and is not responsible for sounding an alarm in the event of a fire.
FALSE
PSM Operating Procedures SummaryPSM Operating Procedures Summary You Must Develop and implement written operating
procedures consistent with the process safety information and addresses at least the following elements:
Initial start-up, normal and temporary operations
Normal and emergency shut-down procedures
Operating limits and consequences of deviation
Hazards presented by the process
You Must Develop and implement You Must Develop and implement written operating written operating proceduresprocedures consistent with the process safety consistent with the process safety information and addresses at least the following information and addresses at least the following elements:elements:
Initial startInitial start--up, normal and temporary operationsup, normal and temporary operations
Normal and emergency shutNormal and emergency shut--down proceduresdown procedures
Operating limits and consequences of deviationOperating limits and consequences of deviation
Hazards presented by the processHazards presented by the process
PSM Safe Work PracticesSummaryPSM Safe Work PracticesSummary Safe Work Practices, Programs &
Procedures must: Be specific to the Covered Process(s) Follow Procedures & Recommendations in
the PHA’s Follow Procedures in the Operating
ProceduresMust be Able to be Tracked Follow Form
Safe Work Practices, Programs & Safe Work Practices, Programs & Procedures must:Procedures must: Be specific to the Covered Process(s)Be specific to the Covered Process(s) Follow Procedures & Recommendations in Follow Procedures & Recommendations in
the PHAthe PHA’’ss Follow Procedures in the Operating Follow Procedures in the Operating
ProceduresProcedures Must be Able to be TrackedMust be Able to be Tracked Follow FormFollow Form
PSM Training SummaryPSM Training Summary PSM Training Programs Must be Developed
for All Necessary Workers and Contractors Verification of Understanding is Required Training Must Be Performed as Follows: Initial training
Prior to work assignment Waved for those already in a process
Refresher training Every three years
All Training Must be Documented
PSM Training Programs Must be Developed PSM Training Programs Must be Developed for All Necessary Workers and Contractorsfor All Necessary Workers and Contractors
Verification of Understanding is RequiredVerification of Understanding is Required Training Must Be Performed as Follows:Training Must Be Performed as Follows: Initial trainingInitial training
Prior to work assignmentPrior to work assignment Waved for those already in a processWaved for those already in a process
Refresher trainingRefresher training Every three yearsEvery three years
All Training Must be DocumentedAll Training Must be Documented
What’s Next?What’s Next?
In the Last Session, we will Cover Contractor Pre-Qualification, Emergency Planning & Response Audits, and EPA Risk Management Plans (RMP)
In the Last Session, we will Cover Contractor Pre-Qualification, Emergency Planning & Response Audits, and EPA Risk Management Plans (RMP)
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